The German National Action Plan on Sustainable Use of Plant Protection Products

1. The GermanNational Action Plan on Sustainable Use of Plant Protection Products PAN Europe Workshop 21-22 January 2009 in Brussels on National Action Plans, Integrated Pest Management and the Common Agricultural Policy Dipl.-Ing. agr. S. Haffmans Susan.haffmans@pan-germany.org

2. Overview • The process and current status • Aims, Measures and Indicators • Weaknesses from the PAN Germany point of view • Coherence: Biodiversity aspects in the Germany NAP • PAN requirements and future tasks

3. The process to develop a strategy March 2002/3 - Ministry for Consumer Protection and Agriculture organised 2 large round table conferences on guiding principles for a future plant protection policy (external moderators) with PAN contribution October 2004 - Minister for Consumer Protection, Food and Agriculture (Künast from the Greens) presents a Reduction Programme Chemical Plant Protection Forum Reduction Programm – regular meetings with participation of all stakeholders (Ministry, farmer organisations, NGOs, food industry, etc) After Elections 2005 – no progress, less stakeholder discussion, modified draft published Febr. 2008 under the conservative Minister April 2008 - Minister for Food, Agriculture and Consumer Protection (Seehofer from the conservatives) presents a National Action Plan on Sustainable Use of Plant Protection Products

4. The German National Action Plan • Aim • To further reduce the potential risks arising from the use of plant protection products (25 % risk reduction by 2020). • To reduce the use of chemical plant protection products „to the necessary minimum“

5. Measures • Keeping the use of chemical plant protection products to the necessary minimum. • Research and Promotion of Innovation Towards Integrated Plant Protection (Innovation Promotion Programme; Increased research and development; application technology, non-chemical plant protection methods, Promoting resistance reearch, crop and sector-specific guidelines on IPM, Hot spot management (identification and elimination) • Improved knowledge and information (Improved plant protection advice etc) • Consumer protection: Reducing of pesticide residues in food

6. Indicators • Treatment index for crops and regions on the bases of NEPTUN crop and regional-spectific data on pesticide use. Treatment index will be used to measure the intensity of chemical plant protection. And Network of reference farms (to assess the levels of plant protection products used annually in order to define the „necessary minimum“). • Risk indicator (Computer-aided model SYNOPS to identifiy relative changes in plant protection product-related risks to aquatic and terrestrial test species.) NEW in discussion: implementation of a benefit index in SYNOPS • NEW: Residues in ecosystems. (chemical and biological monitoring, e.g. using monitoring results obtained under the Water Framework Directive.„Available data will be used wherever possible“.) • Residues in food. NEW in discussion: Re-intreduction of the <1% MRL target (domestic and import produces) • Plant protection Index PIX (cross-system indicator) PIX

7. The German Plant Protection Index PIX

8. Weaknesses from the PAN Germany point of view • The NAP is a step back compared to the former Reduction Program. - No target set for quantitative use reduction - Residue target: <1% exceedance of MRLs taken out • The “necessary minimum” is jet not defined for main crops (wheat), it is not orientated on the “best practice farm” but on the average pesticide use, environmental aspects play a minor role, it is mainly defined by economic aspects. • The given risk oriented aim of “25 % risk reduction by 2020 according to SYNNOPS” is hardly helpful. SYNOPS calculates only theoretical risks based on assumed probabilities. The transferability to given situations in praxis/on the field is challenged even by the responsible authorities (baseline 1996-2005) • Missing timetables and quantitative targets in general • No financial instrument

9. The German National Action Plan and the protection of Biodiversity Aim: Term „Biodiversity“ is missing. Reference to the aims of the National Strategy on Biological Diversity not visisble. Measures: No concrete measures for the protection of biodiverity No concideration of „endangered species“ (besonders geschützter Arten“ (§ 6 PSchG) • Indicators: No specific indicators for biodiversity. • Epigeous species and parasitoid beneficial species are not taken into account Weaknesses from the PAN Germany point of view

10. PAN requirements and future tasks • Re-Introduction of residue aim: exceeding of MRL < 1% (domestic and imports) • General reduction of pesticide residues in food. • Introduction of aims and timetables to a general reduction of pesticide use: - Reduction of the use intensiy of 25-30% (as mesured by the treatment frequency Index) in 5 Years. • Use-reduction/restriction (amount, time and area) for pesticides of high concern (cut-off pesticides and candidates of substitutions and hazard pesticides in WFD) • Protection of Biodiversity: Set up of specific aims and indicators • Guidelines on how to reduce the impact on non target species and habitats • Lobbying for an improvement of the German NAP especially regarding aims & time frames (following wind from EU Regulation!) and consideration of biodiversity • Lobbying for a broad and strong participation of stakeholders

11. ? Arguments and questions raising from the last meeting of the German Forum NAP Dec. 2008 ? ? • “Multiple residues are a sign of best practice (Good Praxis of Plant Protection )” and an indicator for practised IPM” • How to deal with pesticides that fall under the cut-off regulation but remain on the market for years? The NAP could define control (monitoring) of and restrictions for their use. (agreed on in Framework Directive FWD) • FWD only refers to cut-off pesticides. What about regulation for substitution candidates? • Idea from ENDURE to include a “benefit” index in the PIX calculation. Weaken the risk indicator? • Biodiversity indicators: Experiences from other MS? ?

12. Thank you! Dipl.-Ing. agr. S. Haffmans

13. IPM in Germany • General recommendations published in the Good Praxis of Plant Protection (guidelines for farmers published by the Ministry) • Currently no official crop or sector specific guidelines from the Ministry or official bodies. • But: Many private IPM standards especially for fruit and vegetable growers (different Labels) • The JKI (former BBA) is working on general mandatory and specific, voluntary IPM standards. No publication by now.